Featured Articles:

Join Us for a May 16, 2019 BVD Webinar: “Is “Power and Control” the New Beneficial Ownership?

What are the new best practices for third-party risk management? Join Michael Volkov, CEO of The Volkov Law Group; Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, a Moody’s Analytics Company; and Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, for a live webinar on Thursday May 16, 2019, at 11 am EST/4 pm BST. Please sign up HERE.  New anti-corruption...

DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions

The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll.  Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for integrating acquisitions and supply chain missteps. In the latest billion-dollar plus settlement, UniCredit Bank S.p.A UC Group), based in Milan, Italy and two subsidiaries, UniCredit Bank AG (UCB AG), a German bank (aka HypoVereinsbank),...

Acteon Pays $441,000 to Settle Two OFAC Enforcement Actions

We can add Acteon to the list of OFAC settlements for 2019, which is quickly turning into a robust sanctions’ enforcement year.  Acteon is a UK based company, which provides subsea services in the oil and gas industry.  (Acteon recently announced the acquisition of Benthic, an Australian owned subsea company, which operates out of Houston, Texas). In the first enforcement action, Acteon and its operating...

The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation

Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at mstankiewicz@volkovlaw.com. Sanctions law can be complex.  The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more.  In order to enforce these laws and regulations, OFAC must necessarily...

Episode 86 – Standard Chartered Bank Pays Over $1 Billion for Sanctions Violations

Global banks are the poster children of sanctions violations and the importance of trade compliance.  At the top of the heap is Standard Chartered Bank. In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New York District Attorney’s (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the United...

NAVEX Global’s 2019 Hotline Benchmark Report

NAVEX Global’s Hotline benchmark report (here) is an excellent annual report which helps companies to understand how well their hotline and incident management system is operating.  The survey is based on over 1 million reports from 2,738 customers.The NAVEX report also is based on all types of reporting avenues, including hotlines and web-based systems. Interestingly, NAVEX noted that overall reporting rates remained consistent with 2016...

OFAC Sanctions Compliance Insights from Standard Chartered Bank Enforcement Action (Part III of III)

The Treasury Department’s Office of Foreign Asset Control (OFAC) has promised to issue guidance on effective sanctions compliance programs.  This is a long-anticipated update to prior information OFAC has released on the same subject. OFAC has raised the stakes for sanctions enforcement, especially with respect to Iran and Venezuela sanctions programs.  So far this year, OFAC has announced a number of significant enforcement actions and...

Standard Chartered Bank’s Continuing Culture Challenges and Sanctions Compliance (Part II of III)

Standard Chartered Bank certainly has its troubles.  You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the global French bank, which paid over $8 billion for pervasive US sanctions violations.  The Justice Department and OFAC have had a target-rich environment when reviewing global bank...

Stephen Cheng and Noah Smith Write on Senator Warren’s Corporate Executive Accountability Proposal

Stephen Cheng and Noah Smith, Associates at The Volkov Law Group, recently published an article on Law 360, How Warren Bill Would Change Liability For Corporate Execs. “If the criminal penalties in the Corporate Executive Accountability Act — recently proposed by Sen. Elizabeth Warren, D-Mass. — ever became law, they would usher in sweeping implications for the way big companies approach their legal compliance efforts.”...

Standard Chartered Pays Over $1 Billion for Continuing Sanctions Violations (Part I of III)

Global banks are the poster children of sanctions violations and the importance of trade compliance.  At the top of the heap is Standard Chartered Bank. In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New York District Attorney’s (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the...